Alioto v. Commissioner

OPINION

KAREN NELSON MOORE, Circuit Judge.

In 2000 and 2001, Petitioner-Appellant David S. Alioto (“Alioto”) spent several hundred thousand dollars of his own money on expenses relating to a new business venture with which he was involved. Although Alioto alleges that he believed he would be reimbursed for the funds expend ed on behalf of the business, he was never fully repaid. Alioto and his wife, Petitioner-Appellant Melanie S. Alioto (together, the “Aliotos”), sought to deduct the .unreimbursed funds as losses on their joint federal income tax return for tax year 2005. Alioto sought to…